Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Dentistry
 
chapter
Regulations Governing the Practice of Dentistry [18 VAC 60 ‑ 21]
Action Administration of sedation and anesthesia
Stage Proposed
Comment Period Ended on 11/13/2020
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Previous Comment     Back to List of Comments
11/13/20  2:25 pm
Commenter: Yousuf Al-Aboosi

Opposing the Change to 3 Person Team for Moderate Sedation Administration
 

I am a recent graduate board eligible periodontist. I completed my dental school at Virginia Commonwealth University and my periodontal residency at University of Alabama at Birmingham. 

I recently joined a private practice in Fredericksburg, VA after a year of private practice in Burlington, VT. In Virginia, all of our sedation cases are performed with monitors which have alarm which sound if any of the patient’s vitals are not within normal limits, we can address situations such as 02 saturation and blood pressure. Additionally, the entire staff is trained in basic life support and as such, and am ACLS certified and we can manage any emergencies which arise using the proper protocol. 

A large number of IV moderate sedation procedures are performed across the Commonwealth of Virginia every day. Moderate sedation is a necessary aspect to the delivery of dental care for anxious and apprehensive patients. The record of safety speaks for itself. Moderate sedation issues are usually minimal since it is already an immensely safe procedure with greater than a 99% successful safety record.  In my professional opinion, the addition of a third person in the room only to monitor the patient is redundant. I do not perceive any added benefits to the patient safety or comfort. There is no empirical evidence that supports the addition of a third person to monitor moderate sedation cases is exponentially better or result in the elimination of any complications. These types of decisions should have an evidence-based approach to support implementation. There is no evidence to support this. Also, I am unaware of any other state in the U.S. that has this requirement. 

With regards to our current environment involving Covid-19, As medical professionals, we are working hard to make safety and comfort a top priority for our patients during these uncertain times. The extraneous addition of a third person in the operatory subjects patients and other employees to increased potential exposure.  We should be working towards safety and a decrease in exposure instead of the opposite. 

Furthermore, the economic impact the requirement would have on a dental office cannot be overlooked. Taking an employee away from their assigned task to simply stare at a monitor is neither productive or necessary. The requirement to add an employee for this unnecessary task will increases the overhead expenses of any dental practice. This expense will be passed on to the patient and as such increase the overall cost associated with dental care. Increased cost to patients could be detrimental in these uncertain times where many Virginians are struggling to stay financially afloat due to the pandemic. Oral healthcare is essential and directly linked to the overall health of an individual. We should be striving to make dental care and medical more accessible instead of less so.  My fear that if this frivolous regulation is required, price for care will increase making dental care less accessible to those who need it most. 

I very much appreciate the opportunity to share this information and my concerns. 

CommentID: 87422